U.S. Department of Transportation

Docket Management Facility 

1200 New Jersey Avenue, SE West Building Ground Floor Room W12-140 

Washington, DC 20590

Petitioner: Swift Air, LLC.

Sections of FAR Affected

Regulation Affected: 14 CFR 61.157(a) 

14 CFR 61 Appendix A Item I(b) 

14 CFR 121.424(a) and (b) and (d)(1) 

14 CFR 121 Appendix E Item I(a) 

14 CFR 121 Appendix F Item I(b) 

Description of Relief Sought: 

Swift Air, LLC for Exemption No. 4416. The exemption permits operators to conduct 

training and checking of pilots of airplanes requiring only two flight crewmembers on the 

required preflight inspection, both interior and exterior, using approved advanced 

pictorial means. 

Discussion

A. Preflight Visual Inspection. The preflight visual inspection is one of the most 

important elements of preparation for flight. The exemptions cited above contemplate 

the use of sophisticated, advanced pictorial systems that exceed the practical limitations 

imposed by use of an actual airplane. Pictorial systems provide the inspector or 

examiner a unique opportunity to evaluate the depth of the subject pilots preflight 

inspection knowledge to an extent not available on static airplanes. End-products are a 

higher degree of proficiency in flight crews and a greater level of safety overall. 

Regulations and the exemptions themselves offer little specific quality criteria for 

reference by inspectors and operators in addressing advanced pictorial systems. The 

following guidance shall apply:

(1) General Characteristics. The FAA must approve each pictorial system in its entirety. 

The following are desirable characteristics: 

(a) a sufficient number of pictures to portray the location and detail of preflight 

inspection items:

(b) capability for random, rapid access to any picture,

(c) still and motion pictures,

(d) distant and close-up pictures,

(e) pictures of each passenger compartment and each preflight inspection item,
(f) depictions of normal and abnormal conditions, and

(g) sequence of pictures should match the flow of the actual preflight inspection.

(2) Specific Characteristics. Experience has shown that the following specific 

characteristics are appropriate. Inspectors should determine that these characteristics 

are included:

(a) Enough pictures should be maintained to permit coverage of a variety of preflight 

items in practical tests.

(b) The aircraft should be shown in a typical prior-to-flight condition, which may include 

support people and equipment which are associated with flight preparation, such as 

fueling, cleaning, and catering.

(c) Nothing should obstruct the view of the preflight item (jetways, fuel trucks, 

workstands, etc.).

(d) The same aircraft, or identical aircraft, should be pictured throughout the pictorial 

series; in some cases use of non-identical aircraft may be justified to depict differences.

(e) Text and voice should match each picture.

(f) Pictorial systems used for testing should be of high quality, including projection 

equipment with random and rapid access capability. Examples of unacceptable quality 

include copy-machine copies of photographs, videotape systems without random and 

rapid access capability, or any other pictorial system that is markedly inferior to use of a 

static airplane.

(g) For testing, sets of pictures should be used which comprise some of those used in 

training, and additional pictures used exclusively for testing.

(h) For testing, abnormal features should not be shown in pictures intended to depict 

normal aircraft conditions.

(i) Unless an abnormal condition is intentionally depicted for testing, the following 

guidelines shall apply:

a. All permanent parts, such as windows and doors, windshield wipers, 

and antennas, should be in place and in normal condition.

b. All removable parts, such as engine cowls and access panels, should be 

in place and in normal condition; engine inlets should be shown with 

covers removed.

i. Wheel well doors, flaps, slats and aerodynamic surfaces 

and other devices should be in the normal on-ground, 

prior-to-flight configuration, and

ii. People and equipment associated with assembly or 

maintenance work should not be pictured.

(j) For testing, enough pictures of abnormal conditions should be maintained to permit 

comprehensive coverage, particularly of those abnormal conditions which are likely to 

be encountered during preflight inspection and those which are potentially unsafe.
(k) For testing, aircraft should be pictured which are typical or representative of the 

specific aircraft on which the pilot certification is to be conducted. For example, slides of 

a B-737-300 should not be used for a certificate applicant trained under a B-737-200 

curriculum; and vice versa.

(3) Standard References. The FAA-approved preflight procedures contained in the 

manufacturers aircraft flight manual, or in the air carriers aircraft flight manual, are the 

standard references for the preflight visual inspection. Those manuals detail the 

essential preflight items and the sequence in which those items should be inspected.

(4) Strategy and Courseware. When using pictorial means, for optimum effectiveness, 

the courseware should be used differently in training and in testing. In general, static 

pictorial displays (pamphlets, murals, etc.), videotape, and interactive computer-based 

instruction (CBI) systems work well in training. On the other hand, slides work well in 

testing. Similarly, when using pictorial means the training strategy is different from the 

testing strategy. In general, during training the trainee should view preflight items in 

normal configurations. This method conveys positive imprinting to a trainee, and it is the 

same method followed when a static airplane is used. (However, it is beneficial to 

discuss abnormal conditions in training). On the other hand, during testing abnormal 

conditions should be introduced in a sufficient number to permit a reliable evaluation of 

the applicant`s preflight ability.

Exemption not Precedent Setting

Swift Air understands that the FAA has granted several exemptions to individual 

operators for similar relief sought by this request. Therefore, since granting the 

exemption is not precedent setting, Swift Air requests that publication of our petition in 

the Federal Register be waived in accordance with Section 11.27(j)(3) as a delay for 

publication and comment procedures in the Federal Register would be detrimental to 

Swift Air. 

Respectfully,

Douglass Chouinard

Chief Pilot

Swift Air, LLC. I5EA212N

dchouinard@flyswiftair.com